Transparency Report 2017 - EY South Africa - Transparency Report 2017 South Africa
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Transparency Report 2017 EY South Africa
Message from the EY South Africa Country Managing Partner and the Assurance Leader 1 About Us 5 Legal structure, ownership and governance 5 Network arrangements 5 Commitment to quality 8 Infrastructure supporting quality 8 Instilled professional values 9 Internal quality control system 10 Client acceptance and continuance 11 Performance of audits 11 Review and consultation 12 Audit partner and Firm rotation 13 Audit quality reviews 15 External quality assurance review 15 Compliance with legal requirements 15 Independence practices 16 Continuing education of audit professionals 18 Revenue and remuneration 19 Financial information 19 Partner remuneration 19 Appendix 1 20 Appendix 2 21 Appendix 3 22
Message from the EY South Africa Country
Managing Partner and the Assurance Leader
Welcome to the 2017 Transparency Report of Ernst & Young Inc. (EY South Africa). We
appreciate that our stakeholders want to understand how we advance audit quality, manage risk
and maintain our independence as auditors. Regular dialogue is important to us, and this report is
one of the ways in which we advise our stakeholders of what we are doing in each of these areas.
Due to EY South Africa’s audits of EU Public Interest Entities (PIEs), we are required to compile
this Transparency Report, which complies with the European Unions’ 8th Company Law Directive,
Yf\o`a[`[gn]jkl`]ÕfYf[aYdq]Yj]f\af_+(Bmf]*()/&Afl`akj]hgjl$qgmoaddd]Yjfegj]
about our internal quality control system: how we instill professional values, how we perform
an audit, our review and consultation processes, our approach to audit quality reviews, and our
independence practices.
Executing high-quality audits continues to be our top priority and is at the heart of our
commitment to serve the public interest. It enables us to grow the global EY network successfully
Ajen Sita and responsibly, while achieving our purpose of building a better working world. Auditors play a
Country Managing Partner vital role in the functioning of capital markets by promoting transparency and supporting investor
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every engagement.
EY South Africa’s reputation is based on and grounded in providing high-quality professional audit
services objectively and ethically to every company we audit. The foundation of our business is
the position of trust we occupy within society as a whole. In South Africa, that society remains
unequal in wealth distribution; unequal in access to employment opportunities; and unfortunately
features high levels of corruption.
EY South Africa is focused on enhancing audit quality and upholding our independence, informed
by several matters including external and internal inspection results. Continuous improvement
of audit quality requires us to challenge approaches to audit execution, and we focus on this by
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in tools to improve what we do, creating the highest-performing teams, and building trust and
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In recent times, a spotlight has been shone on the audit profession and the media has reported
extensively on the role of auditors and the purpose of an audit. There is much to be done to
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and ethics.
Lance Tomlinson Much has also been reported in the media about state capture in South Africa. On a weekly basis
Country Assurance Leader we are learning about irregular business practices and relationships. Companies in South Africa
and abroad have been forced to review their business practices and relationships in order to
safeguard their brands. We have seen local and global banks close accounts of individuals and
companies, and a growing number of companies are reviewing who they do business with.
As EY, we have committed ourselves to a purpose of building a better working world for our
people, our clients and our communities. Now more than ever we are called upon to live this
purpose. In order to protect our own brand from the risks prevalent in the market, there are a
number of actions we have undertaken.
1
1
Firstly, we are performing comprehensive reviews of our own internal risk management practices with particular emphasis on client
& engagement acceptance as well as those policies that deal with our independence. Whilst we consider these policies to be strong
and globally consistent, we are enhancing delegation of authority levels and introducing additional safeguards for work we deliver,
particularly in the public sector. Secondly, we are engaging all our stakeholders including regulators and our clients in order to
understand their evolving positions with respect to their own organisations as well as sharing information about risk management
at EY. Thirdly, we are increasing engagement with our own partners and staff in the areas of ethics and independence. In addition
to the annual independence, ethics, and anti-bribery & corruption training that all people at EY are required to undertake, we have
provided supplementary classroom and web-based learning updates on these topics, including the recently released Non-Compliance
with Laws and Regulations (NOCLAR) standard. We take strong action against partners and staff who do not live our values, or who
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dismissals. Lastly, we are actively seeking ways to bring relevant role-players together in discussions on changes that will enhance the
transparency and build the strong reputation of our profession.
The current business climate in South Africa is both unprecedented and dynamic. Selecting the right clients to serve is critical. This
requires information, judgement, robust policies and practices, and an appropriate level of oversight. There is no single publicly
available watch-list of entities believed to be undertaking corrupt practices, nor have there been any prosecutions on the theme of state
capture. Consequently, it is impossible to state with certainty that we have a complete list of companies allegedly implicated in state
capture. That said, we have been actively monitoring public reports and making decisions about companies we will not serve. Through
this external monitoring exercise, we have to date compiled a list of over 550 entities in the market place that we are now monitoring.
We have recently performed a review of all clients (over 2,500 in each year), both audit and non-audit, that EY South Africa has
served in the last 5 years and have compared these against the list of over 550 entities referred to above, to identify whether we have
performed work for those entities. Through this exercise, we have concluded that we have not provided services for companies that we
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]Y[`g^l`]hj][]\af_-q]Yjk$o]a\]flaÕ]\+[da]flkaf*(),$*()-Yf\*().j]kh][lan]dq$^jgeo`geo][memdYlan]dq]Yjf]\^]]k
of less than R1.5m of our total revenues, and which we today consider to be companies in the private sector that we would no longer
want to perform services for. In none of these cases did we act as internal or external auditors. Furthermore, they were short duration,
non-repeat assignments that were routine in nature and involved advice on the application of accounting and reporting standards, data
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about our independence and compliance with professional standards as well as the high quality of the work performed in delivering our
services.
Over the coming months there is likely to be more information in the public domain. We will monitor these developments and work
with the relevant stakeholders to improve transparency and governance in the profession and aim to root out corrupt practices from
our society. Where we believe that a client relationship poses a risk to our brand, we will, consistent with past practice, discontinue the
relationship.
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to come. One such development is the requirement for the adoption and implementation of Mandatory Audit Firm Rotation (MAFR),
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will now reside with the Audit Committee of that entity. To discharge this responsibility, the audit committee will require additional
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15 October 2017.
2
Now more than ever is the time to remind ourselves of our Purpose – “building a better working world”. We are committed to building
our distinctive brand, ensuring that we are a favoured employer, ensuring positive relationships with our stakeholders, and playing our
role to improve our communities.
We are also proud to have been recognised as a Top Employer in Africa, and are especially delighted that EY South Africa was ranked
*Y[jgkkl`][gmfljq$Y^l]jGd\EmlmYd&L`akeYc]kmkl`]d]Y\af_hjg^]kkagfYdk]jna[]kÕjeafKgml`9^ja[Y&O]`Yn]Z]]fhdY[]\af
the top 10 for the past 12 years.
This year, EY South Africa also received recognition at the Business Engage Gender Mainstreaming Awards. EY was the overall winner
in the categories of Diversity & Transformation and Economic Empowerment and the winner in the category of Women Empowerment
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and in the category of Young Women.
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Kgml`9^ja[YfD]Y\]jk`ahl]YeYj]ZdY[c&Gn]jYddYlYÕjed]n]degj]l`Yf-( g^gmjklY^^Yj]ZdY[c&:%::==akYfafl]_jYl]\
socio-economic process aimed at redressing the imbalances of the past by seeking to substantially and equitably transfer and confer
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progress towards this imperative. We will use this accomplishment to accelerate progress towards being fully representative of the
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commitment to the transformation imperative of the country and the development and upliftment of our people.
We encourage all our stakeholders — including investors, audit committee members, companies and regulators — to continue to engage
with us on our strategy as well as any of the matters covered in this report.
Ajen Sita Lance Tomlinson
Country Managing Partner Country Assurance Leader
EY Inc. EY Inc.
28 November 2017
EY’s purpose: building a better working world
EY is committed to doing its part in building a better working world.
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outstanding leaders who team to deliver on our promises to stakeholders. In so doing, we play a critical role in building a better working world
for our people, our clients and our communities.
3
3
4
About Us
Legal structure, ownership and =Q?e]eZ]jÕjekYj]_jgmh]\aflg^gmj_]g_jYh`a[9j]Yk2
9e]ja[Yk39kaY%HY[aÕ[3=mjgh]$Ea\\d]=Ykl$Af\aYYf\9^ja[Y
governance =E=A9!3Yf\BYhYf&L`]9j]Yk[gehjak]YfmeZ]jg^J]_agfk$
o`a[`[gfkaklg^e]eZ]jÕjekgjk][lagfkg^l`gk]Õjek&
In South Africa, Ernst & Young Incorporated is a personal liability
EY South Africa is part of the EMEIA Area, which comprises EYG
company incorporated in the Republic of South Africa and is a
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e]eZ]jÕjeg^=jfkl Qgmf_?dgZYdDaeal]\$YMC[gehYfq
and Africa. Within the EMEIA Area, there are 12 Regions. EY
limited by guarantee (EYG). In this report, we refer to ourselves as
South Africa is part of the Africa Region (Southern Cluster).
“EY South Africa,” “we,” “us” or “our.” EY refers collectively to
Ernst & Young (EMEIA) Limited (“EMEIA Limited”), an English
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company limited by guarantee, is the principal coordinating entity
The EY South Africa companies are owned by their directors. ^gjl`]=Q?e]eZ]jÕjekafl`]=E=A99j]Y&=E=A9Daeal]\
^Y[adalYl]kl`][ggj\afYlagfg^l`]k]ÕjekYf\[ggh]jYlagf
EY South Africa also includes the following entities which are EYG
between them, but it does not control them. EMEIA Limited is a
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• Ernst & Young Advisory Services (Pty) Ltd provide any professional services.
• Ernst & Young Services (Pty) Ltd Each Region elects a Regional Partner Forum (RPF), whose
representatives advise and act as a sounding board to Regional
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leadership. The partner elected as Presiding Partner of the
RPF also serves as the Region’s representative on the Global
As at 30 June 2017, the South Africa Executive Governance Council.
comprised:
Ajen Sita Managing Partner
NYd
Network arrangements Americas
Regions 10
EMEIA
Regions 12
Asia-Pacific
Regions 5
Japan
Regions 1
Countries 31 Countries 98 Countries 22 Countries 1
EY is a global leader in assurance, tax, transaction and advisory
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than 150 countries share a commitment to building a better
working world, united by shared values and an unwavering
commitment to quality, integrity and professional skepticism. In
today’s global market, the integrated EY approach is particularly
important in the delivery of high-quality multinational audits,
which can span multiple jurisdictions.
This integrated approach enables EY to develop and draw upon
the range and depth of expertise required to deliver such complex
audits.
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among them. EYG does not provide services, but its objectives Independent Non-Executives
include the promotion of exceptional high-quality client service by Up to six Independent Non-Executives (INEs) are appointed from
e]eZ]jÕjekogjd\oa\]& outside EY. The INEs are senior leaders from both the public and
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and responsibilities as members of EYG are governed by the backgrounds. They bring to the global organisation, and the GGC,
regulations of EYG and various other agreements. l`]ka_faÕ[YflZ]f]Õlg^l`]ajnYja]\h]jkh][lan]kYf\\]hl`g^
knowledge. The INEs also form a majority of the Public Interest
The structure and principal bodies of the global organisation Sub-Committee of the GGC, which addresses public interest
\mjaf_l`]q]Yj]f\]\+(Bmf]*()/Yj]\]k[jaZ]\Z]dgo&L`]q matters, including stakeholder dialogue. The INEs are nominated
j]Ö][ll`]hjaf[ahd]l`Yl=Q$YkY_dgZYdgj_YfakYlagf$`YkY by a dedicated committee.
common shared strategy.
Global Executive
The Executive includes the Global Executive (GE), its committees The Global Executive (GE) brings together EY’s leadership
and teams, and the leadership of the four Areas. This streamlined functions, services and geographies. It is chaired by the Chairman
structure allows EY to enhance its global scale and the delivery and CEO of EYG, and includes its Global Managing Partners of
of consistent exceptional client service worldwide, with the Client Service and Business Enablement; the Area Managing
Executive responsible for coordinating a global approach to Partners; the global functional leadership for Talent and Finance;
strategy, quality, risk management, business planning and the leaders of the global service lines — Assurance, Advisory, Tax
priorities. and Transaction Advisory Services; the Global Leader for Public
At the same time, the network also operates on a Regional Hgda[q3Yf\gf]=Q?e]eZ]jÕjehYjlf]jgfjglYlagf&
level. This operating model allows for greater stakeholder focus The GE also includes the Chair of the Global Accounts Committee
afl`]*0J]_agfk$h]jeallaf_e]eZ]jÕjeklgZmad\kljgf_]j and the Chair of the Emerging Markets Committee, as well as a
relationships with clients and others in each country, and be more representative from the Emerging Markets practices.
responsive to local needs.
The GE and the GGC approve nominations for the Chairman and
Global Governance Council CEO of EYG, and ratify appointments of the Global Managing
The Global Governance Council (GGC) is the main oversight body Partners. The GE also approves appointments of Global Vice
of EYG. It comprises one or more representatives from each ;`Yajk&L`]??;jYlaÕ]kl`]Yhhgafle]flkg^Yfq?dgZYdNa[]
J]_agf$gl`]je]eZ]jÕjehYjlf]jkYkYl%dYj_]j]hj]k]flYlan]k Chair who serves as a member of the GE.
and up to six independent non-executives (INEs). The Regional
representatives, who otherwise do not hold senior management
roles, are elected by their RPFs for a three-year term, with
provision for one successive reappointment. The GGC advises
EYG on policies, strategies and the public interest aspects of
its decision-making. The approval of the GGC is required for a
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6
The GE’s responsibilities include the promotion of global E]eZ]jÕjekYj]kmZb][llgj]na]okl`Yl]nYdmYl]l`]aj
objectives and the development, approval, and, where relevant, adherence to EYG requirements and policies governing issues
implementation of: such as independence, quality and risk management, audit
e]l`g\gdg_q$Yf\`meYfj]kgmj[]k&E]eZ]jÕjekmfYZd]lg
• Global strategies and plans
meet the quality commitments and other EYG membership
• Common standards, methodologies and policies to be promoted requirements may be subject to separation from the EY
oal`afe]eZ]jÕjek organisation.
• People initiatives, including criteria and processes for
admission, evaluation, development, reward and retirement of
partners
• Quality improvement and protection programs
• Proposals regarding regulatory matters and public policy
• Hgda[a]kYf\_ma\Yf[]j]dYlaf_lge]eZ]jÕjekÌk]jna[]g^
international clients, business development, markets and
branding
• EY’s development funds and investment priorities
• =Q?ÌkYffmYdÕfYf[aYdj]hgjlkYf\Zm\_]lk
• GGC recommendations
The GE also has the power to mediate and adjudicate disputes
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GE committees
Established by the GE and bringing together representatives
from the four Areas, the GE committees are responsible for
making recommendations to the GE. In addition to the Global
Audit Committee, there are committees for Global Markets and
Investments, Global Accounts, Emerging Markets, Talent, Risk
Management, Assurance, Advisory, Tax, and Transaction Advisory
Services.
Global Practice Group
This group brings together the members of the GE, GE
committees and Regional leaders. The Global Practice Group
seeks to promote a common understanding of EY’s strategic
objectives and consistency of execution across the organisation.
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to pursue EY’s objectives, such as the provision of high-quality
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the implementation of global strategies and plans, and maintain
the prescribed scope of service capability. They are required to
comply with common standards, methodologies and policies,
including those regarding audit methodology, quality and
risk management, independence, knowledge sharing, human
resources, and technology.
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professional practices in accordance with applicable professional
and ethical standards, and all applicable requirements of law. This
commitment to integrity and doing the right thing is underpinned
by the EY Global Code of Conduct and EY values.
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several other agreements covering aspects of their membership
in the EY organisation, such as the right and obligation to use the
EY name, and the sharing of knowledge.
7
7Commitment to quality
Infrastructure supporting about EY people, clients and processes, and they are readily
accessible for consultation with audit engagement teams.
quality Additional resources often augment the Global Professional
Practice group, including networks of professionals focused on:
Quality in our service lines
Vision 2020+, which sets out EY’s purpose, ambition and • Internal-control reporting and related aspects of the EY audit
kljYl]_q$[Yddk^gj=Q?e]eZ]jÕjeklghjgna\]]p[]hlagfYd methodology
client service worldwide. This is supported by an unwavering
• 9[[gmflaf_$Ym\alaf_Yf\jakcakkm]k^gjkh][aÕ[af\mklja]kYf\
commitment to quality and service that is professionally
sectors
and globally consistent, and means service that is based on
objectivity, professional skepticism, and adherence to EY and • =n]fl%kh][aÕ[akkm]kafngdnaf_Yj]Ykg^[anadYf\hgdala[Ydmfj]kl3
professional standards. or sovereign debt and related accounting, auditing, reporting
and disclosure implications
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delivering quality engagements. EY service lines manage the • General engagement issues and how to work effectively with
overall process for quality reviews of completed engagements audit committees
and input for the quality of in-process engagements, which helps
Risk management
achieve compliance with professional standards and EY policies.
Responsibility for the delivery of high-quality service and
Vision 2020+ has reinforced the ownership of quality by the ownership of the risks associated with quality is placed with the
service lines, including audit. It has also resulted in increased e]eZ]jÕjek&9egf_gl`]jl`af_k$l`]?dgZYdJakcEYfY_]e]fl
clarity around the role of risk management in policies and Leader helps oversee the management of these risks by the
practices that support and improve quality audit. e]eZ]jÕjek$Yko]ddYkgl`]jjakckY[jgkkl`]gj_YfakYlagfYk
part of the broader Enterprise Risk Management framework.
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compliance with EY policies and procedures for assurance E]eZ]jÕjehYjlf]jkYj]Yhhgafl]\lgd]Y\jakceYfY_]e]fl
services. afalaYlan]kafZgl`l`]k]jna[]daf]kYf\e]eZ]jÕjek$kmhhgjl]\
by other staff and professionals. The Global Risk Management
Professional Practice
Leader is responsible for establishing globally consistent risk
The Global Vice Chair of Professional Practice, referred to as the
management execution priorities and enterprise-wide risk
Global Professional Practice Director (PPD), is overseen by the
eYfY_]e]fl&L`]k]hjagjala]k[Yk[Y\]lge]eZ]jÕjek$
Global Vice Chair of Assurance and works to establish global audit
and their execution is monitored through an Enterprise Risk
quality control policies and procedures. Each of the Area PPDs
Management program.
is overseen by the Global PPD and the related Area Assurance
Leader. This helps provide greater assurance as to the objectivity ?dgZYd[gfÕ\]flaYdalqhgda[q
of audit quality and consultation processes. Hjgl][laf_[gfÕ\]flaYdaf^gjeYlagfakaf_jYaf]\afl`]]n]jq\Yq
Y[lanala]kg^=Q?e]eZ]jÕjek&J]kh][l^gjafl]dd][lmYd[YhalYd
The Global PPD also leads and oversees the Global Professional
and all other sensitive and restricted information is required
Practice group. This is a global network of technical subject
by the Global Code of Conduct, which provides a clear set of
matter specialists in accounting and auditing standards, who
principles to guide the behaviours expected of all EY people.
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L`]?dgZYd;gfÕ\]flaYdalqHgda[q^mjl`]j\]lYadkl`akYhhjgY[`lg
and perform various practice monitoring and risk management
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activities.
restricted data. This policy provides added clarity for EY people
The Global PPD oversees development of the EY Global Audit and forms the fundamental element of broader guidance that
Methodology (EY GAM) and related technologies so that af[dm\]kc]qhgda[a]kgf[gfÖa[lkg^afl]j]kl$h]jkgfYd\YlYhjanY[q
they are consistent with relevant professional standards and and records retention. Other guidance includes:
regulatory requirements. The Global Professional Practice
• Social media guidance
group also oversees the development of the guidance, training
Yf\egfalgjaf_hjg_jYekYf\hjg[]kk]kmk]\Zqe]eZ]jÕje • Information-handling requirements
professionals to execute audits consistently and effectively. The
• Cfgod]\_]%k`Yjaf_hjglg[gdk
Global, Area and Region PPDs, together with other professionals
o`gogjcoal`l`]eaf]Y[`e]eZ]jÕje$Yj]cfgod]\_]YZd]
8Components of the audit quality control program We have deployed world-class tools that enhance the quality and
In the following sections, we describe the principal components of value of our audits. Our ability to deliver consistency is based
the EY South Africa audit quality control program: in part on the use of EY Canvas, our online audit platform. EY
• Instilled professional values Canvas was broadly deployed beginning in 2015 and is now
used globally. It better supports audit execution, streamlines
• Internal quality control system communications and enables us to provide a seamless audit.
• Client acceptance and continuance We recently launched the EY Canvas Client Portal, which adds to
• Performance of audits the leading-edge tools already offered to our auditors. In addition,
we have deployed the 2017 Audit Milestones Program globally,
• Review and consultation which establishes the use of Milestones on selected Public Interest
• Audit partner rotation Entity (PIE) audits as one important step to improving results and
sustaining quality across engagements.
• Audit quality reviews
Af*().$=Q\]n]dgh]\Yf]logjcg^ImYdalq=fYZd]e]flD]Y\]jk
• External quality-assurance reviews (QELs) and created a Global Audit Quality Committee.
• Compliance with legal requirements These and other SAQ initiatives have helped us to continue to
drive quality improvements. They demonstrate that audit quality
Instilled professional values is the single most important factor in our decision-making and the
key measure on which our professional reputation stands.
Sustainable Audit Quality
Quality is the foundation for exceptional client service. It is what Tone at the top
we pride ourselves on. It is integral to our work and central to Senior EY and EY South Africa leadership are responsible
gmjj]khgfkaZadalqlghjgna\][gfÕ\]f[]lgl`][YhalYdeYjc]lk& for setting the right tone at the top and demonstrating EY’s
Delivering quality is at the heart of all we do and supports our commitment to building a better working world through behavior
purpose of building a better working world for our people, our and actions. While the tone at the top is vital, our people also
[da]flkYf\gmj[geemfala]k&L`akakj]Ö][l]\afl`]KmklYafYZd] understand that quality and professional responsibility start with
Audit Quality (SAQ) program, which is the highest priority for our them. Our shared values, which inspire our people and guide
Assurance practice. them to do the right thing, and our commitment to quality are
embedded in who we are and in everything we do.
=Y[`e]eZ]jÕjel`YleYc]kmhgmj_dgZYdkljm[lmj]ak
committed to providing high-quality audits. In 2015, we The EY approach to business ethics and integrity is contained
launched the SAQ initiative throughout our Assurance practices. in the EY Global Code of Conduct and other policies, and is
SAQ establishes a governance structure and is focused on embedded in the EY culture of consultation, training programs
continuously improving our audit process. and internal communications. Senior management regularly
reinforces the importance of performing quality work, complying
We use the word “sustainable” in SAQ to demonstrate that this with professional standards, adhering to our policies, leading by
is not a one-off short-term initiative, but an ongoing process of example and through various communications. Also, EY’s quality
improvement. EY has had a common audit methodology for some review programs assess professional service as a key metric in
time; now we have a common language and processes regarding evaluating and rewarding all professionals.
audit quality.
The EY culture strongly supports collaboration and places
There are six components to SAQ: tone at the top, strengthening special emphasis on the importance of consultation in dealing
h]ghd][YhYZadala]k$kaehdaÕ[Ylagf$Ym\all][`fgdg_qYf\\a_alYd$ with complex or subjective accounting, auditing, reporting,
enablement and quality support, and accountability. SAQ is regulatory and independence matters. We believe it is important
aehd]e]fl]\Zq]Y[`e]eZ]jÕje$Yf\ak[ggj\afYl]\Yf\ to determine that engagement teams and clients correctly follow
overseen globally. consultation advice, and we emphasise this when necessary.
We constantly reinforce the importance of the six components,
and discuss them with every Regional Assurance leader and
every partner. Audit quality and the key elements of SAQ are The consistent stance of EY South Africa has
something every senior manager, manager and team member been that no client is more important than
must understand and be committed to implementing locally. SAQ our professional reputation — the reputation
is essential to all our goals and ambitions. of EY South Africa and the reputation of each
of our professionals.
O]`Yn]eY\]ka_faÕ[Yflhjg_j]kkl`jgm_`K9I&=QÌk
afl]jfYdYf\]pl]jfYdafkh][lagfÕf\af_k_dgZYddqYj]k`goaf_
improvement, and we are producing greater consistency in
execution.
9
9Code of conduct We recognise that in today’s environment — characterised by
We promote a culture of integrity among our professionals. The continuing globalisation and the rapid movement of capital — the
EY Global Code of Conduct provides a clear set of principles quality of our audit services has never been more important.
that guide our actions and our business conduct, and are to be As part of EY Vision 2020+, we continue to invest heavily in
followed by all EY personnel. The Code of Conduct is divided into developing and maintaining our audit methodology, tools and
Õn][Yl]_gja]k2 other resources needed to support quality service delivery.
• Working with one another While the market and stakeholders continue to demand
`a_`imYdalqYm\alk$l`]qYdkg\]eYf\af[j]Ykaf_dq]^Õ[a]fl
• Working with clients and others
and effective delivery of audit services. In addition to the
• Acting with professional integrity investments mentioned, EY continues to seek ways to improve
l`]]^^][lan]f]kkYf\]^Õ[a]f[qg^alkYm\ale]l`g\gdg_qYf\
• Maintaining our objectivity and independence
processes, while improving audit quality.
• Respecting intellectual capital
We work to understand where our audit quality may not be up
Through our procedures to monitor compliance with the EY to our own expectations and those of stakeholders, including
Global Code of Conduct, and through frequent communications, ]pl]jfYdYm\alÕjej]_mdYlgjk&O]k]]clgd]Yjf^jge]pl]jfYd
we strive to create an environment that encourages all personnel and internal inspection activities and to identify root causes of
to act responsibly, including reporting misconduct without fear of adverse quality occurrences to enable us continually to improve
retaliation. audit quality, and we believe that taking effective and appropriate
actions to improve quality is important.
The EY Ethics Hotline provides our people, clients and others
gmlka\]g^l`]gj_YfakYlagfoal`Ye]Yfklgj]hgjl[gfÕ\]flaYddq Effectiveness of the quality control system
activity that may involve unethical or improper behaviour and
EY has designed and implemented a comprehensive set of global
that may be in violation of professional standards or otherwise
audit quality control policies and practices. These policies and
inconsistent with the EY Global Code of Conduct. The hotline is
practices meet the requirements of the International Standards
gh]jYl]\ZqYf]pl]jfYdgj_YfakYlagfl`Ylhjgna\]k[gfÕ\]flaYd
on Quality Control issued by the International Auditing and
and, if desired, anonymous hotline reporting services for
Assurance Standards Board (IAASB). EY South Africa has adopted
companies worldwide.
these global policies and procedures, and has supplemented
When a report comes into the EY Ethics Hotline, either by them as necessary to comply with local laws and professional
phone or internet, it receives prompt attention. Depending on _ma\]daf]k$Yf\lgY\\j]kkkh][aÕ[Zmkaf]kkf]]\k&
the content of the report, appropriate individuals from Risk
We also execute the EY Audit Quality Review (AQR) program to
Management, Talent, Legal or other functions are involved to
evaluate whether our system of audit quality control has operated
address the report. The same procedures are followed for matters
effectively so as to provide reasonable assurance that EY South
that are reported outside of the EY Ethics Hotline.
Africa and our people comply with applicable professional and
internal standards and with regulatory requirements.
Our values: who we are The results of the AQR program and external inspections are
People who demonstrate integrity, evaluated and communicated within EY South Africa to provide
respect and teaming the basis for continual improvement in audit quality, consistent
with the highest standards in the profession.
People with energy, enthusiasm and
The GE is responsible for implementing quality improvement and
the courage to lead
protection programs across EY. As such, it reviews the results of
our internal AQR program and external regulatory reviews, as well
People who build relationships based
as any key actions designed to address areas for improvement.
on doing the right thing
The recent results of such monitoring, together with the recent
feedback from independent regulatory inspection visits, provide
Internal quality control system EY South Africa with a basis to conclude that our internal control
systems are designed appropriately and are operating effectively.
EY South Africa’s reputation for providing high-quality
professional audit services independently, objectively and
ethically is fundamental to our success as independent auditors.
We continue to invest in initiatives to promote enhanced
objectivity, independence and professional skepticism. These are
fundamental attributes of a high quality audit.
At EY South Africa, our role as auditors is to provide assurance
gfl`]^Yajhj]k]flYlagfg^l`]ÕfYf[aYdklYl]e]flkg^l`]
[gehYfa]ko]Ym\al&O]Zjaf_lg_]l`]jimYdaÕ]\l]Yeklghjgna\]
our services, drawing on our proven experience across industry
sectors and services. We continually strive to improve our quality
and risk management processes so that the quality of our service
is at a consistently high level.
10Client acceptance and In our annual client continuance process, we review our service
delivery and ability to continue to provide quality service, and
continuance [gfÕjel`Yl[da]flkk`Yj]=QKgml`9^ja[YÌk[geeale]fllg
imYdalqYf\ljYfkhYj]f[qafÕfYf[aYdj]hgjlaf_&L`]hYjlf]jaf
EY policy charge of each audit, together with our Assurance leadership,
The EY Global Client Acceptance and Continuance Policy sets out annually reviews our relationship with the audit client to
hjaf[ahd]k^gje]eZ]jÕjeklg\]l]jeaf]o`]l`]jlgY[[]hlY determine whether continuance is appropriate.
new client or a new engagement, or to continue with an existing
As a result of this review, certain audit engagements are
client or engagement. These principles are fundamental to
a\]flaÕ]\Ykj]imajaf_Yf\Yj]l`]fkmZb][l]\lgY\\alagfYd
maintaining quality, managing risk, protecting our people and
oversight procedures during the audit (close monitoring), and
meeting regulatory requirements. The objectives of the policy are
some audit clients are discontinued. As with the client acceptance
to:
process, our local PPD is involved in the client continuance
• Establish a rigorous process for evaluating risk and making process and must agree with the continuance decisions for
decisions to accept or continue clients or engagements engagements designated for close monitoring.
• Meet applicable independence requirements Both client acceptance and client continuance decisions consider
the engagement team’s assessment of whether
• A\]fla^qYf\\]YdYhhjghjaYl]dqoal`Yfq[gfÖa[lkg^afl]j]kl
the company’s management could pressure us to accept
• Identify and decline clients or engagements that pose excessive
inappropriate accounting, auditing and reporting conclusions
risk
to undermine quality. Considerations and conclusions on the
• Require consultation with designated professionals to identify integrity of management are essential to acceptance and
Y\\alagfYdjakceYfY_]e]flhjg[]\mj]k^gjkh][aÕ[`a_`%jakc continuance decisions.
factors
• Comply with legal, regulatory and professional requirements Performance of audits
AfY\\alagf$l`]=Q?dgZYd;gfÖa[lkg^Afl]j]klHgda[q\]Õf]k 9khYjlg^=QNakagf*(*(#$=Q`Ykafn]kl]\ka_faÕ[Yfldqaf
_dgZYdklYf\Yj\k^gjY\\j]kkaf_[Yl]_gja]kg^hgl]flaYd[gfÖa[lk improving audit methodologies and tools, with the goal of
of interest and a process for identifying them. It also includes performing the highest-quality audits in the profession. This
hjgnakagfk^gjeYfY_af_hgl]flaYd[gfÖa[lkg^afl]j]klYkima[cdq investment is consistent with EY’s goal to have the leading audit
Yf\]^Õ[a]fldqYkhgkkaZd]l`jgm_`l`]mk]g^YhhjghjaYl] hjY[la[]kafl`]hjg^]kkagfZq*(*(Yf\j]Ö][lkl`][geeale]fl
safeguards. Such safeguards range from obtaining a client’s lgZmad\af_ljmklYf\[gfÕ\]f[]afl`][YhalYdeYjc]lkYf\af
[gfk]fl^gj=Q?e]eZ]jÕjeklgY[l^gjloggjegj][da]flklg economies the world over.
\][dafaf_Yf]f_Y_]e]fllgYnga\Yfa\]flaÕ]\[gfÖa[l&
Audit methodology
L`]=Q?dgZYd;gfÖa[lkg^Afl]j]klHgda[qYf\Ykkg[aYl]\_ma\Yf[] EY GAM provides a global framework for delivering high quality
were updated in early 2015. The updates take into account the audit services through the consistent application of thought
increasing complexity of engagements and client relationships, processes, judgments and procedures in all audit engagements.
and the need for speed and accuracy in responding to clients.
Making risk assessments, reconsidering and modifying them
They also align with the latest International Ethics Standards
as appropriate, and using these assessments to determine the
Board for Accountants (IESBA) standards.
nature, timing and extent of audit procedures are fundamental to
Putting policy into practice EY GAM. The methodology also emphasises applying appropriate
We use the EY Process for Acceptance of Clients and professional skepticism in the execution of audit procedures. EY
=f_Y_]e]flk H9;=!$Yf]oafljYf]l%ZYk]\kqkl]e$^gj]^Õ[a]fldq GAM is based on International Standards on Auditing (ISAs) and
coordinating client and engagement acceptance and continuance is supplemented in South Africa to comply with the local auditing
Y[lanala]kafdaf]oal`_dgZYd$k]jna[]daf]Yf\e]eZ]jÕjehgda[a]k& standards and regulatory or statutory requirements.
PACE takes users through the acceptance and continuance
An EY auditor is presented with a version of EY GAM organised
j]imaj]e]flk$Yf\a\]flaÕ]kl`]hgda[a]kYf\j]^]j]f[]k
by topic and designed to focus the audit strategy on the
to professional standards needed to assess both business
ÕfYf[aYdklYl]e]fljakck$Yf\l`]\]ka_fYf\]p][mlagfg^l`]
opportunities and associated risks.
appropriate audit response to those risks. EY GAM consists of
As part of this process, we carefully consider the risk two key components: requirements and guidance, and supporting
characteristics of a prospective client or engagement and several ^gjekYf\]pYehd]k&L`]j]imaj]e]flkYf\_ma\Yf[]j]Ö][l
due diligence procedures. Before we take on a new engagement both audit standards and EY policies. The forms and examples
gj[da]fl$o]\]l]jeaf]o`]l`]jo][Yf[geealkm^Õ[a]fl include leading practice illustrations, and assist in performing and
resources to deliver quality service, especially in highly technical documenting audit procedures.
areas, and if the services the client wants are appropriate for us
to provide.
11
11Mkaf_l][`fgdg_q$=Q?9E[YfZ]ÉhjgÕd]\ÊgjlYadgj]\lghj]k]fl EY Helix is our suite of data analytic tools for use in audits.
the relevant requirements and guidance, depending on the nature Analytics is transforming the audit by analysing larger
g^l`]]flalqZ]af_Ym\al]\&>gj]pYehd]$l`]j]Yj]hjgÕd]k^gj populations of audit-relevant data, identifying unseen patterns
listed entities and for those considered non-complex entities. and trends in that data, and helping to direct our audit efforts.
The use of analytics also allows us to obtain better perspectives,
Enhancements to the audit methodology are made regularly to
richer insights and a deeper understanding of transactions and
address new standards, emerging auditing issues and matters,
areas of risk.
implementation experiences, and external and internal inspection
j]kmdlk&Af*().$=Q?9EoYkmh\Yl]\lgaf[dm\]l`]f]oYf\ We have developed analytics that cover our clients’ end-to-end
revised ISAs dealing with auditor reporting, other information business operating cycles, supported by analytics-based audit
af[dm\]\afYfYffmYdj]hgjlYf\ÕfYf[aYdklYl]e]fl\ak[dgkmj]k& programs to aid their application.
EY GAM was also enhanced by adding guidance to address
Using our analytics, our engagement teams can enhance
common questions from audit teams and issues arising from
their audit risk assessment, enabling the audit of higher-risk
inspections.
transactions, and assisting our people in asking better questions
In addition, we monitor current and emerging developments YZgmlYm\alÕf\af_kYf\]nYdmYlaf_l`]gml[ge]k&
continually, and issue timely audit planning and other reminders.
Formation of audit engagement teams
These reminders emphasise areas noted during inspections as
EY South Africa policies require an annual review of partner
well as other key topics of interest to our regulators, including
assignments by our Assurance leadership to make sure that
the International Forum of Independent Audit Regulators (IFIAR).
the professionals leading listed-company audits possess the
These topics include professional skepticism, group audits,
appropriate competencies (i.e., the knowledge, skills and abilities)
revenue recognition and engagement quality reviews.
lg^mdÕddl`]aj]f_Y_]e]flj]khgfkaZadala]k$Yf\Yj]af[gehdaYf[]
EY GAM requires compliance with relevant ethical requirements, with applicable auditor rotation regulations.
including independence from the company we audit.
The assignment of professionals to an audit engagement is
Technology also made under the direction of our Assurance leadership.
Our audit engagement teams use technology to assist in Factors considered when assigning people to audit teams
executing and documenting the work performed in accordance af[dm\]]f_Y_]e]flkar]Yf\[gehd]palq$kh][aYdak]\af\mkljq
with EY GAM. knowledge and experience, timing of work, diversity, continuity,
and opportunities for on-the-job training. For more complex
:]_affaf_afdYl]Õk[Ydq]Yj*()-$o]dYmf[`]\=Q;YfnYk$
engagements, consideration is given to whether specialised or
our global audit platform that lies at the heart of the audit and
additional expertise is needed to supplement or enhance the audit
enables us to provide a high quality audit. This was launched
engagement team.
gfYh`Yk]\ZYkakY[jgkk=Q?e]eZ]jÕjek_dgZYddq$oal`
deployment completed in 2017. EY Canvas is built using HTML5, In many situations, internal specialists are assigned as part of the
state-of-the-art technology for web applications. This allows us audit engagement team to assist in performing audit procedures
to provide heightened data security and to evolve our software to and obtaining appropriate audit evidence. These professionals are
respond to changes in the accounting profession and regulatory used in situations requiring special skills or knowledge, such as
environment. information systems, asset valuation and actuarial analysis.
L`jgm_`l`]mk]g^hjgÕd]im]klagfk$Ym\al]f_Y_]e]flkaf=Q
;YfnYkYj]YmlgeYla[Yddq[gfÕ_mj]\oal`af^gjeYlagfj]d]nYfl Review and consultation
to the company’s listing requirements and industry. This helps
Reviews of audit work
to keep our audit plans customised and up-to-date, and provides
EY policies describe the requirements for timely and direct
direct linkage to our audit guidance, professional standards
senior professional participation, as well as the level of review
and documentation templates. EY Canvas is built with a fresh,
required for the work performed. Supervisory members of an
clear design and user interface that allows users to visualise
audit engagement team perform a detailed review of the audit
risks and their relationship to our planned response and work
documentation for accuracy and completeness. Senior audit
performed in key areas. It also enables a linkage for our group
executives and engagement partners perform a second-level
Ym\all]Yeklg[geemfa[Yl]afl]j%g^Õ[]jakckYf\afkljm[lagfk
review to determine adequacy of the audit work as a whole, and
so that the primary audit team can direct execution and monitor
l`]j]dYl]\Y[[gmflaf_Yf\ÕfYf[aYdklYl]e]flhj]k]flYlagf&9
performance of the group audit. The predecessor audit support
lYphjg^]kkagfYdj]na]okl`]ka_faÕ[YfllYpYf\gl`]jj]d]nYfl
lggd$?9Ep$oaddZ]\][geeakkagf]\afgmj*()0Õk[Ydq]Yj&
working papers. For listed and certain other companies, an
EY Canvas includes a Client Portal, released in April 2017, to engagement quality reviewer (described below) reviews important
assist teams in communicating with clients and streamline their Yj]Ykg^Y[[gmflaf_$ÕfYf[aYdj]hgjlaf_Yf\Ym\al]p][mlagf$Yk
client requests. Mobile applications, integrated with EY Canvas, o]ddYkl`]ÕfYf[aYdklYl]e]flkg^l`][gehYfqo]Ym\alYf\gmj
o]j]j]d]Yk]\afÕk[Ydq]Yj*()/l`YlYkkaklgmjh]ghd]afl`]aj audit report.
audit work; for example, in monitoring the status of the audit,
capturing audit evidence securely and performing inventory
observations.
Audit engagement teams use other software applications,
forms and templates during various phases of an audit to
assist in executing procedures, making and documenting audit
conclusions, and performing analysis.
12The nature, timing and extent of the reviews of audit work depend Audit engagement team resolution process for
on many factors, including: differences of professional opinion
EY has a collaborative culture that encourages and expects
• The risk, materiality, subjectivity and complexity of the subject
people to speak up, without fear of reprisal, if a difference of
matter
professional opinion arises or if they are uncomfortable about a
• The ability and experience of the audit team members matter relating to a client engagement. Policies and procedures
preparing the audit documentation are designed to empower members of an audit engagement team
lgjYak]Yfq\akY_j]]e]flkj]dYlaf_lgka_faÕ[YflY[[gmflaf_$
• The level of the reviewer’s direct participation in the audit work
auditing or reporting matters.
• The extent of consultation employed
These policies are made clear to people as they join EY, and
Our policies also describe the roles and responsibilities of we continue to promote a culture that reinforces a person’s
each audit engagement team member for managing, directing responsibility and authority to make their own views heard, and
and supervising the audit, as well as the requirements for seek out the views of others.
documenting their work and conclusions.
Differences of professional opinion that arise during an audit are
generally resolved at the audit engagement team level. However,
Consultation is built into the
a^Yfqh]jkgfafngdn]\afl`]\ak[mkkagfg^Yfakkm]akfglkYlakÕ]\
decision-making process; it is not
with the decision, they refer it to the next level of authority until
just a process to provide advice.
Y_j]]e]flakj]Y[`]\gjYÕfYd\][akagfakeY\]&
For complex and sensitive matters, we have a formal process Furthermore, if the engagement quality reviewer makes
requiring consultation outside of the audit engagement team recommendations that the engagement partner does not accept
with other personnel who have more experience or specialised or the matter is not resolved to the reviewer’s satisfaction, the
knowledge, primarily Professional Practice and Independence audit report is not issued until the matter is resolved. EY policies
personnel. In the interests of objectivity and professional require documentation of disagreements and their resolution.
skepticism, our policies require members of Professional Practice,
Independence and certain others to withdraw from a consultation
if they currently serve, or have recently served, the client to
Audit partner and Firm rotation
which the consultation relates. EY supports mandatory audit partner rotation to help strengthen
auditor independence. EY South Africa complies with the
Our policies also require that we document all consultations,
audit partner rotation requirements of the code of the IESBA,
including written concurrence from the person or persons
Independent Regulatory Board for Auditors (IRBA) in South
consulted, in order to demonstrate their understanding of the
Africa, and the Companies Act of South Africa, 2008, as well
matter and its resolution.
as the U.S. Securities and Exchange Commission (SEC), where
Engagement quality reviews required. EY South Africa supports audit partner rotation because
Engagement quality reviews are performed by audit partners it provides a fresh perspective and promotes independence
in compliance with professional standards for audits of all listed from company management, while retaining expertise and
companies and those considered higher risk. Engagement quality knowledge of the business. Audit partner rotation, combined with
j]na]o]jkYj]]ph]ja]f[]\hjg^]kkagfYdkoal`ka_faÕ[YflkmZb][l independence requirements, enhanced systems of internal quality
matter knowledge. They are independent of the engagement controls and independent audit oversight, helps strengthen
l]YeYf\YZd]lghjgna\]gZb][lan]]nYdmYlagfg^ka_faÕ[Yfl independence and objectivity, and are important safeguards of
accounting, auditing and reporting matters. In no circumstances audit quality.
may the responsibility of the engagement quality reviewer be
For PIEs where rotation of the audit partner is not mandated
delegated to another individual.
by local independence regulation or is less restrictive than
The engagement quality review spans the entire engagement the IESBA requirements, the EY Global Independence Policy
cycle, including planning, risk assessment, audit strategy and requires the lead engagement partner and the engagement
execution. Policies and procedures for the performance and quality reviewer to be rotated after seven years. For a new PIE
\g[me]flYlagfg^]f_Y_]e]flimYdalqj]na]okhjgna\]kh][aÕ[ (including a newly listed company) client, the lead engagement
guidelines on the nature, timing and extent of the procedures to partner and the engagement quality reviewer may remain in
be performed, and the required documentation evidencing their place for an additional two years before rotating off the team,
completion. Our PPD approves all engagement quality review if they have served the client for six or more years prior to the
assignments for listed companies and those considered higher listing. Following rotation, the partner may not resume the lead
risk. or engagement quality review role until at least two years have
elapsed.
We employ tools to track partner rotation that enable effective
monitoring of compliance with requirements. We have also
implemented a process for partner rotation planning and
decision-making that involves consultation with, and approvals by,
our Professional Practice and Independence professionals.
13
13AfBmf]*()/l`]Af\]h]f\]flJ]_mdYlgjq:gYj\^gj9m\algjk The results of the Global AQR program, the in-country AQR
(IRBA) announced the requirements for the adoption and results, external practice-monitoring and inspection activities
implementation of Mandatory Audit Firm Rotation (MAFR). The are evaluated and communicated to improve quality. Any quality
jmdaf_`YkZ]]f_Yr]ll]\aflgdYo$Yf\ak]^^][lan]^gjl`]Ym\alg^ improvement plans describe the follow-up actions to be taken,
ÕfYf[aYdq]Yjk[gee]f[af_gfgjY^l]j)9hjad*(*+& the people responsible, the timetable and deadlines, and sign-
off on completed actions. Measures to resolve audit quality
The ruling is effective for the audit of Public Interest Entity (PIE)
matters noted from the Global and in-country AQR program,
[da]flk&A^YHA=`YkZ]]fYm\al]\Zql`]kYe]Õje^gj)(gj
regulatory inspections and peer reviews are addressed by
egj][gfk][mlan]q]YjkZ]^gj]l`]ÕfYf[aYdq]Yj[gee]f[af_
Assurance leadership and our PPD. The actions are monitored
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by our PPD and Assurance leadership. These programs provide
appointment, and will then be subject to a 5 year “cooling off”
important practice monitoring feedback for our continuing quality
period. EY South Africa is already working to assess the impact of
improvement efforts.
this ruling.
The results of the AQR program, together with the most recent
Audit quality reviews independent regulatory inspection visits, combined with other
ongoing monitoring procedures, provide EY South Africa with a
The EY Global AQR program is the cornerstone of the EY process basis to conclude that our internal quality control systems are
to monitor audit quality. EY South Africa executes the Global designed appropriately and are operating effectively, and that no
AQR program, reports results and develops responsive actions kqkl]ea[\]Õ[a]f[a]k`Yn]Z]]fa\]flaÕ]\&
plans. The primary goal of the program is to determine whether
systems of quality controls, including those of EY South Africa,
are appropriately designed and followed in the execution of audit
External quality assurance
engagements to provide reasonable assurance of compliance with
policies and procedures, professional standards, and regulatory
review
requirements. The Global AQR program complies with guidelines EY South Africa’s audit practice and our registered statutory
in the International Standard on Quality Control No. 1 (ISQC auditors are subject to regular inspection by the IRBA. As part of
No. 1), as amended, and is supplemented where necessary to its inspections, the IRBA evaluates quality control systems and
comply with South African professional standards and regulatory reviews selected engagements.
requirements. It also aids EY South Africa’s continual efforts to
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identify areas where we can improve our performance or enhance
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our policies and procedures.
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Implemented annually, the program is coordinated and monitored
The IRBA reviews a sample of audit engagements annually.
by representatives of the Global PPD network, with oversight by
Global Assurance leadership. L`]H;9G:[gf\m[lkafkh][lagfk]n]jq+q]Yjk&L`]dYklg^Õ[]%
level and engagement level review by the PCAOB took place in
The engagements reviewed each year are selected on a risk-
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based approach, emphasising audit engagements that are
dYj_]$[gehd]pgjg^ka_faÕ[YflhmZda[afl]j]kl&L`]?dgZYd9IJ O]j]kh][lYf\Z]f]Õl^jgel`]]pl]jfYdj]_mdYlgjqafkh][lagf
hjg_jYeaf[dm\]k\]lYad]\jakc%^g[mk]\Õd]j]na]ok[gn]jaf_ process. We thoroughly evaluate points raised during the
a large sample of listed and non-listed audit engagements to inspection in order to identify areas where we can improve audit
measure compliance with internal policies and procedures, EY quality and put necessary action plans in place to address these.
GAM requirements, and relevant local professional standards Together with our AQR process, external inspections aid us in
and regulatory requirements. It also includes reviews of a sample making our audits and related control processes of the highest
of non-audit engagements. These measure compliance with quality in the interests of investors and other stakeholders.
the relevant professional standards and internal policies and
Information on the above-mentioned regulators can be found at
procedures that should be applied in executing non-audit services.
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In addition, practice-level reviews are performed to assess
compliance with quality control policies and procedures in the
functional areas set out in ISQC No. 1. The Global AQR program Compliance with legal
complements external practice monitoring and inspection
activities, such as regulatory inspection programs and external requirements
peer reviews.
The EY Global Code of Conduct provides a clear set of standards
AQR reviewers and team leaders are selected for their skills and that guide our actions and business conduct.
professional competence in accounting and auditing, as well
EY South Africa complies with applicable laws and regulations,
as their industry specialisation; they often work in the Global
and EY’s values underpin our commitment to doing the right
AQR program for a number of years and are highly skilled in
thing. This important commitment is supported by a number of
the execution of the program. Team leaders and reviewers are
policies and procedures, explained in the paragraphs below.
assigned to inspections outside of their home location and are
independent of the audit teams reviewed. Anti-bribery
The EY Global Anti-bribery Policy provides EY people with
direction around certain unethical and illegal activities. It
emphasises the obligation to comply with anti-bribery laws and
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